In the result, appeal of the assessee in ITA No
Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण वर्ा अपीलधर्थी प्रत्यर्थी / Ita No. / A.Y. / Appellant / Respondent
134/- being 1/4th of such disallowance of Rs. 2,05,28,536/-. 12. In our opinion, the approach of the learned Assessing Officer as well as the learned CIT(A) on this issue is not correct. It is an admitted fact that the assessment in the instant case is under section 153A of the Act and the addition was based